Does the purchase of a closely-held business from a seller who becomes a foreign official violate the FCPA?  The DOJ’s first Opinion Procedure Release of the year examines whether a company’s payment to the foreign official, the former chief executive and minority owner of a foreign subsidiary of the company, to complete a previously contemplated buyout (but at a higher price than originally agreed) violates the FCPA.  This article scrutinizes the facts in the request and the DOJ’s decision and reasoning.  See “DOJ Clarifies Bounds of Humanitarian Aid Benefitting Foreign Officials in FCPA Opinion Release” (Jan. 8, 2014).